Commission Guidelines on Good Distribution Practice of Medicinal

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EUROPEAN COMMISSION
HEALTH AND CONSUMERS DIRECTORATE-GENERAL
Public Health and Risk Assessment
Pharmaceuticals
Brussels,
SANCO/C8/AM/an D(2010) 380358
Commission Guidelines on Good Distribution Practice of Medicinal
Products for Human Use
Legal basis for publishing the guidelines: Article 84 of Directive 2001/83/EC on the
Community
code
relating
to
medicinal
products
for
human
use.
The proposed guidelines will replace the Guidelines on Good Distribution Practice of
Medicinal Products for Human Use published in 1994 in the Official Journal of the
European Communities1 .
Status of the document: revision for public consultation
Deadline for public consultation: 31 December 2011
Reasons for change: The content of the Guidelines on Good Distribution Practice
published in 1994 is no longer adequate. It needs to be reviewed to take into account
advancements of practices for an appropriate storage and distribution of medicinal
products in the European Union. Moreover, it should take into account the amendments
to the Community Code which have been introduced with Directive 2011/62/EU of the
European Parliament and of the Council amending Directive 2001/83/EC on the
Community code relating to medicinal products for human use, as regards the prevention
of the entry into the legal supply chain of falsified medicinal products2.
Deadline for coming into operation: 6 months after publication
1
2
OJ 1994, C63, p. 3.
OJ 01.07.2011, L174, p. 74-87
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111
Table of Contents
INTRODUCTION............................................................................................................... 4
CHAPTER 1 QUALITY MANAGEMENT ....................................................................... 5
Quality System ............................................................................................................ 5
Management of Outsourced Activities........................................................................ 6
Management Review and Monitoring......................................................................... 6
Quality Risk Management........................................................................................... 6
CHAPTER 2 PERSONNEL................................................................................................ 8
Responsible Person...................................................................................................... 8
Other Personnel ........................................................................................................... 9
Training ....................................................................................................................... 9
Hygiene ..................................................................................................................... 10
CHAPTER 3 PREMISES AND EQUIPMENT ................................................................ 11
Premises..................................................................................................................... 11
Temperature and Environment Control..................................................................... 12
Equipment ................................................................................................................. 12
Computerised Systems .............................................................................................. 12
Qualification and Validation ..................................................................................... 13
CHAPTER 4 DOCUMENTATION.................................................................................. 14
General ...................................................................................................................... 14
CHAPTER 5 OPERATIONS ............................................................................................ 15
Qualification of Suppliers ......................................................................................... 15
Qualification of Customers ....................................................................................... 16
Marketing authorisation ............................................................................................ 16
Receipt of Goods ....................................................................................................... 16
Storage....................................................................................................................... 17
Segregation of Goods ................................................................................................ 17
Destruction of obsolete Goods .................................................................................. 18
Picking....................................................................................................................... 18
Packing ...................................................................................................................... 18
Delivery ..................................................................................................................... 18
Export ........................................................................................................................ 18
2
CHAPTER 6 COMPLAINTS, RETURNS, SUSPECTED FALSIFIED
MEDICINAL PRODUCTS AND MEDICINAL PRODUCT RECALLS ............... 20
Complaints................................................................................................................. 20
Returned Medicinal Products .................................................................................... 20
Suspected falsified Medicinal Products .................................................................... 21
Medicinal Product Recalls ........................................................................................ 22
CHAPTER 7 CONTRACT OPERATIONS...................................................................... 23
Contract Giver ........................................................................................................... 23
Contract Acceptor...................................................................................................... 23
Contract ..................................................................................................................... 23
CHAPTER 8 SELF-INSPECTIONS................................................................................. 25
Self-Inspections ......................................................................................................... 25
CHAPTER 9 TRANSPORTATION ................................................................................. 26
Transportation ........................................................................................................... 26
Containers, packaging and labelling ......................................................................... 27
Transportation of Products requiring special Conditions.......................................... 27
Temperature Control during Transport ..................................................................... 28
CHAPTER 10 SPECIFIC PROVISIONS FOR BROKERS ............................................. 29
Quality Management System .................................................................................... 29
Personnel ................................................................................................................... 29
Documentation .......................................................................................................... 29
Annex:
Glossary of Terms
3
Introduction
The present guidelines are based on Articles 84 and 85a(3) of Directive 2001/83/EC of the
European Parliament and of the Council of 6 November 2001 on the Community code relating
to medicinal products for human use3 ("Directive 2001/83/EC').
The wholesale distribution of medicinal products is an important activity in the integrated
supply chain management. Today’s distribution network for medicinal products is increasingly
complex and involves many players. The quality and the integrity of medicinal products can be
affected by a lack of adequate control over the numerous activities, which occur during
distribution and it is also necessary to address the threat that falsified medicinal products
pose to the distribution channel. It is necessary to exercise control over the entire chain of
distribution objectives by observing good manufacturing practice of medicinal products. This
policy ensures that products manufactured in, or imported into the European Union are of the
appropriate quality. This level of quality should be maintained throughout the distribution
network without any alteration.
According to Article 1(17) of Directive 2001/83/EC, wholesale distribution is "all activities
consisting of procuring, holding, supplying or exporting medicinal products, apart from
supplying medicinal products to the public.
Any person engaging in the activity of a wholesale distributor has to be holder of a wholesale
distribution authorisation.
Possession of a manufacturing authorisation shall include authorisation to distribute the
medicinal products covered by the authorisation.
The definition of wholesale distribution is independent as to whether that distributor is
established or operating in specific customs areas, such as in free zones or in free
warehouses. All obligations related to wholesale distribution activities (such as exporting,
holding, or storing) also apply to these actors.
Other actors, such as brokers, also may play a role in the distribution channel of medicinal
products.
Article 80(g) of Directive 2001/83/EC provides that distributors must comply with the
principles and guidelines of good distribution practice (GDP). Manufacturers distributing their
own products should also comply with GDP. According to Article 85b, persons brokering
medicinal products shall be subject to certain provision applicable to wholesale distributors, as
well as specific provisions for brokering.
The relevant sections of these guidelines should also be considered for implementation by,
among others, governments, regulatory bodies, international procurement organisations and
donor agencies, as well as all parties involved in any aspect of distribution of medicinal
products.
This Guideline is presented as a set of basic requirements in different Chapters providing
details about specific areas of activity.
3
OJ L 311, 28.11.2001, p. 67
4
Chapter 1 Quality Management
Principle
Wholesale distributors must maintain a quality system setting out responsibilities, processes
and risk management measures in relation to their activities.4 They should ensure that the
quality of medicinal products and the integrity of the distribution chain is maintained
throughout the distribution process.
All distribution activities should be clearly defined and systematically reviewed and all critical
steps of distribution processes and significant changes should be validated.
The quality system should incorporate quality risk management principles. The attainment of
this quality objective is the responsibility of the organisation’s senior management and
requires their leadership and active participation and should be supported by the commitment
of staff.
Quality System
1.1
The system for managing quality should encompass the organisational structure,
procedures, processes and resources, as well as activities necessary to ensure
confidence that the product delivered is not adulterated during storage and/or
transportation.
1.2
A responsible person should be appointed by the management for each distribution site,
who should have defined authority and responsibility for ensuring that a quality system
is implemented and maintained.
1.3
Senior management of the distributor should ensure that all parts of the quality system
are adequately resourced with competent personnel, and suitable and sufficient
premises, equipment and facilities.
1.4
The size and complexity of distributor’s activities should be taken into consideration
when developing the quality management system or modifying an existing one.
1.5
The quality system should be fully documented and its effectiveness monitored. All
quality related activities should be defined and documented. A quality manual or
equivalent documentation approach should be established.
1.6
The quality system should be organised in a way, that it reflects the size and structure
of the organisation.
1.7
A change control system should be in place for management of changes to critical
processes. This system should incorporate quality risk management principles.
1.8
The quality system should ensure that:
i) medicinal products are procured, held, supplied or exported in a way that is
compliant with the requirements of GDP;
ii) management responsibilities are clearly specified;
iii) products are delivered to the right recipients within a satisfactory time period;
iv) quality related activities are recorded at the time they are performed;
4
Article 80 point h of Directive 2001/83/EC
5
v) deviations from established procedures are documented and investigated;
vi) appropriate corrective and preventive actions (CAPA) are taken to correct
deviations and prevent them in line with the principles of quality risk management.
Management of Outsourced Activities
1.9
The quality management system should extend to the control and review of any
outsourced activities. These processes should incorporate quality risk management and
include:
i) Assessing prior to outsourcing operations, the suitability and competence of the other
party to carry out the activity and checking authorisation status, if required;
ii) Defining the responsibilities and communication processes for quality related
activities of the involved parties. For outsourced activities, this should be included in a
written agreement between the contract giver and contract acceptor;
iii) Monitoring and reviewing of the performance of the contract acceptor, and the
identification and implementation of any needed improvements on a regular basis.
Management Review and Monitoring
1.10 Senior
management
should
have
a
formal
process
for
reviewing
the
quality
management system on a periodic basis. The review should include:
i) Measurement of achievement of quality management system objectives;
ii) Assessment of performance indicators that can be used to monitor the effectiveness
of processes within the quality management system, such as complaints, deviations,
CAPA, changes to processes; feedback on outsourced activities; self assessment
processes including risk assessments, and audits; external assessments such as
regulatory inspections and findings and customer audits.
iii) Emerging regulations, guidance and quality issues that can impact the quality
management system;
iv) Innovations that might enhance the quality management system;
v) Changes in business environment and objectives.
1.11 The outcome of this management review of the quality management system should be
timely and effectively communicated.
Quality Risk Management
1.12 Quality risk management is a systematic process for the assessment, control,
communication and review of risks to the quality of medicinal products. It can be
applied both proactively and retrospectively.
1.13 Quality risk management should ensure that the evaluation of the risk to quality is
based on scientific knowledge, experience with the process and ultimately links to the
protection of the patient. The level of effort, formality and documentation of the process
should be commensurate with the level of risk. Examples of the processes and
6
applications of quality risk management can be found inter alia in the EU Guidelines to
Good Manufacturing Practice5 or publications of the International Conference on
Harmonisation of Technical Requirements for Registration of Pharmaceuticals for Human
Use ('ICH').
5
http://ec.europa.eu/health/documents/eudralex/vol-4/index_en.htm
7
Chapter 2 Personnel
Principle
The establishment and maintenance of a satisfactory quality management system and the
correct distribution of medicinal products relies upon people. For this reason, there must be
sufficient competent personnel to carry out all the tasks, which are the responsibility of the
wholesale distributor. Individual responsibilities should be clearly understood by the
individuals and recorded. All personnel should be aware of the principles of GDP that affect
them and should receive initial and continuing training relevant to their responsibilities.
Responsible Person
2.1
The wholesale distributor must designate a person as Responsible Person6. The
Responsible Person should fulfil his/her responsibilities personally and should be
permanently available. The Responsible Person should meet the conditions provided for
by the legislation of the Member State concerned.
2.2
The
written
job
description
of
the
Responsible
Person
should
define
his/her
authorisation to take the decisions with regard to his/her responsibilities. The wholesale
distributor should give the Responsible Person defined authority, resources and
responsibility needed to fulfil his/her duties.
2.3
The qualifications of the Responsible Person should meet the conditions provided by the
legislation of the Member State concerned and should be appropriate to fulfil the
assigned duties. A degree in Pharmacy is desirable. He/she should have appropriate
competence and experience as well as knowledge and training on GDP.
2.4
The Responsible Person should carry out his/her activities personally in order to ensure
the wholesale distributor can demonstrate GDP compliance and that public service
obligations are met.
2.5
His/her responsibilities include, but are not limited to:
i)
ensuring that a quality management system is implemented and maintained;
ii) focussing on the management of authorised activities and the accuracy and quality
of records;
iii) approving the initial and continuous training programme for all personnel involved in
distribution activities;
iv) coordinating and performing promptly any recall operations of medicinal products;
v) ensuring that relevant customer complaints are dealt with effectively;
vi) performing the qualification and approval of suppliers and customers;
vii) authorising the return to saleable stock of any returned medicines;
6
Article 79 of Directive 2001/83/EC
8
viii)approving any contract between the Contract Giver and the Contract Acceptor which
specifies their respective responsibilities relating to wholesale distribution and/or
transportation of medicinal products;
ix) ensuring that self inspections are performed at appropriate regular intervals
following a prearranged programme and necessary corrective measures are put in
place;
x) delegating his/her duties when absent and keeping appropriate records relating to
any delegation;
xi) being involved in any decision to quarantine or dispose of returned, rejected,
recalled or falsified products;
xii) ensuring that any additional requirements imposed on certain products by national
law are adhered to, as foreseen in Article 83 of Directive 2001/83/EC.
Other Personnel
2.6
There should be an adequate number, in respect of the scope of its activities, of
competent personnel, involved in all stages of the wholesale distribution activities of
medicinal products in order to ensure that the quality of the product is maintained.
2.7
The organisational structure of the distributor should be defined in an organisational
chart. The responsibility, role and interrelationships of all personnel should be clearly
indicated.
2.8
The responsibilities and roles of employees working in key positions to medicinal
products quality should be defined in written job descriptions, in which the deputyship
arrangements of employees are also laid out.
2.9
The duties placed on any individual should not be so extensive as to present
unacceptable risk to product quality.
Training
2.10 All personnel involved in wholesale distribution activities should be qualified in GDP
requirements by training and should have the appropriate competence and experience
prior to commencing their tasks.
2.11 In addition, training should include aspects of product identification and avoidance of
falsified medicines entering the supply chain.
2.12 Personnel dealing with medicinal products requiring more stringent handling such as
hazardous products, radioactive materials as well as products presenting special risks of
abuse, narcotics or psychotropic substances, or temperature sensitive products should
be given specific training.
2.13 Personnel should receive initial and continuing training relevant to their tasks, based on
written standard operating procedures (SOPs) and in accordance with a written training
programme. The Responsible Person should also maintain his/her competence in GDP
through regular training.
2.14 A record of all training should be kept, and the practical effectiveness of training should
be periodically assessed and documented.
9
Hygiene
2.15 Appropriate procedures relating to personnel hygiene, relevant to the activities to be
carried out, should be established and observed. Such procedures should cover health,
hygiene and clothing.
2.16 The storage of food, drink, smoking materials or medication for personal use in the
storage areas should be prohibited.
10
Chapter 3 Premises and Equipment
Principle
Wholesale distributors must have suitable and adequate premises, installations and
equipment7, so as to ensure proper conservation and distribution of the medicinal products.
Premises
3.1
The premises should be designed or adapted to ensure that good storage conditions are
maintained. They should be suitably secure, structurally sound and of sufficient capacity
to allow for the safe storage and handling of the medicinal products. Storage areas
should be provided with adequate lighting to enable all operations to be carried out
accurately and safely.
3.2
Where premises are not directly operated by the wholesale distributor, a contract should
be in place and the premises should be covered by a wholesale distribution
authorisation.
3.3
There should be segregated areas designated for the storage of products awaiting
further decisions as to their fate. These include any product suspected of falsification,
returned products, rejected product, product awaiting disposal and recalled product. The
appropriate degree of security should be applied in these areas to ensure that such
items remain separate from saleable stock.
3.4
Medicinal products not intended for the Union market should be kept in segregated
areas.
3.5
Where specific storage conditions are required, control should be adequate to maintain
all parts of the relevant storage area within defined temperature, humidity or light
parameters.
3.6
Special attention should be paid to the storage of products with specific handling
instructions as specified in national law. Special storage conditions (and special
authorisations) may be required for such products (e.g. narcotics).
3.7
Radioactive materials and other hazardous products, as well as products presenting
special risks of fire or explosion (e.g. pressurized gases, combustibles, flammable
liquids and solids) should be stored in a dedicated area(s) subject to appropriate safety
and security measures.
3.8
Receiving and dispatch bays should protect products from prevailing weather conditions.
There should be adequate separation between the receipt and dispatch areas and
storage areas. Reception areas where deliveries are examined at receipt should be
designated and suitably equipped.
3.9
Unauthorised access to all areas of the authorised premises should be prevented.
Prevention measures would usually include, but not be limited to, a monitored intruder
alarm system and appropriate access control.
7
Article 79(a) of Directive 2001/83/EC
11
3.10 Premises and storage facilities should be clean and free from litter and dust. Cleaning
instructions and records should be in place. Cleaning equipment should be chosen and
used in order not to be a source of contamination.
3.11 Facilities should be designed and equipped so as to afford protection against the entry
of insects, rodents or other animals. A preventive pest control programme should be in
place.
3.12 Rest, wash and refreshment rooms for employees should be adequately separated from
the storage areas.
Temperature and Environment Control
3.13 Suitable equipment and procedures should be in place to ensure adequate control of the
environment of medicinal products during storage. Environmental factors to be
considered include, but are not limited to, temperature, humidity, and cleanliness of the
premises.
3.14 Storage areas should be temperature mapped under representative conditions and
should take into account seasonal variations. An initial mapping should be carried out
prior to the commencement of use. The mapping exercise should be repeated according
to the results of a risk assessment exercise or whenever significant modifications are
made to the facility or the temperature controlling equipment. Temperature monitoring
equipment should be located according to the results of the mapping exercise.
Equipment
3.15 All equipment used for storage and distribution of medicinal products should be
designed, located and maintained to a standard which suits its intended purpose.
Planned preventive maintenance should be in place for key equipment vital to the
functionality of the operation.
3.16 Equipment used to control or to monitor the environment of the medicinal product,
should be calibrated and their correct operation and suitability for purpose verified at
defined intervals by the appropriate methodology.
3.17 Calibration of equipment should be traceable to a primary standard. Appropriate alarm
systems should be in place to provide alerts when there are deviations from pre-defined
storage conditions. Alarm levels should be appropriately set and alarms should be
regularly tested to ensure adequate functionality.
3.18 Repair, maintenance, and calibration operations of equipment should be carried out in
such a way that the integrity of the medicinal products is not compromised.
3.19 Adequate records of repair, maintenance and calibration activities for key equipment
should be made and the results should be retained. Relevant pieces of equipment would
include (but not be limited to) cold stores, refrigerators, thermo hygrometers, or other
temperature and humidity recording devices, air handling units and any equipment
utilised in conjunction within the onward supply chain.
Computerised Systems
3.20 Before a computerised system is brought into use, it should be confirmed as being
capable of achieving the desired results.
12
3.21 A written detailed description of the system should be available (including diagrams
where appropriate). This should be kept up-to-date. The document should describe the
principles, objectives, security measures and scope of the system and the main
features, how the computerised system is used and the way it interacts with other
systems.
3.22 Data should only be entered into the computerised system or amended by persons
authorised to do so.
3.23 Data should be secured by physical or electronic means against wilful or accidental
damage. Stored data should be checked for accessibility, durability and accuracy.
3.24 Data should be protected by backing up at regular intervals. Back up data should be
stored for a period stated in national legislation but at least 5 years at a separate,
secure location.
3.25 Procedures to be followed if the system fails or breaks down should be defined. This
should include systems for the restoration of data.
Qualification and Validation
3.26 Wholesale distributors should identify what qualification and/or validation work is
necessary to demonstrate control of key aspects of their activities. The scope and
extent of such validations should be determined by a documented risk assessment
approach. Validation activities should be planned and documented. The plan should
specify acceptance criteria.
3.27 Prior to implementation and after any significant changes or upgrades, systems should
be validated to ensure correct installation and operation.
3.28 A validation report should be prepared summarising the results obtained and
commenting on any observed deviations. The principles of corrective and preventive
actions (CAPA) should be applied where necessary. Evidence of satisfactory validation
and acceptance of a process or piece of equipment should be produced and approved by
appropriate personnel.
3.29 Re-qualification of equipment following repair or maintenance should be considered
dependant on the scope of the changes made. Such decisions should be justified
utilising a risk based approach.
13
Chapter 4 Documentation
Principle
Good documentation constitutes an essential part of the quality management system. Clearly
written documentation prevents errors from spoken communication and permits tracing of
batch history. Instructions, procedures, and records should be free from errors and each
employee should have access to such instructions and procedures concerning his or her
activities at any time.
General
4.1
Documentation comprises all written procedures, instructions, contracts, records and
data, in paper or in electronic form.
4.2
Documentation should be sufficiently comprehensive with respect to the scope of the
distributor’s activities and in a language understood by personnel. It should be written
in clear and unambiguous language.
4.3
Documentation should be approved, signed and dated by appropriate authorised
persons, as required. It should not be hand-written; although, where documents require
the entry of data, sufficient space should be provided for such entries.
4.4
Any alteration made in the documentation should be signed and dated; the alteration
should permit the reading of the original information. Where appropriate, the reason for
the alteration should be recorded.
4.5
Documents should be retained for a period stated in national legislation but not shorter
than 5 years.
4.6
All documentation should be readily available.
4.7
Attention should be paid to maintaining the SOP system so as to ensure the use of valid
and approved procedures. Documents should have unambiguous contents; title, nature
and purpose should be clearly stated. Documents should be reviewed regularly and kept
up-to-date. Version control should be applied to SOPs and superseded versions should
be archived. After revision of documents a system should exist to prevent inadvertent
use of the superseded versions. Superseded or obsolete SOP documents should be
removed from workstations.
4.8
Records
4.9
Records must be kept either in the form of purchase/sales invoices, delivery slips, or on
computer or in any other form, for any transaction in medicinal products received,
supplied or brokered.
4.10 Records should include the following information: date; name of the medicinal product;
quantity received, supplied or brokered; name and address of the supplier, broker or
consignee, as appropriate; and batch number where required.
4.11 Records should be made at the time each operation is taken and in such a way that all
significant activities or events are traceable.
14
Chapter 5 Operations
Principle
All actions taken by the distributor should ensure that the identity of the medicinal product is
not lost and that wholesale distribution of medicinal products is handled according to the
specifications given on the packaging information. The wholesale distributor should use all
means available to ensure that the source of all arriving products is known to minimise the
risk of falsified medicinal products entering the legal supply chain.
All medicinal products distributed in the EU by a wholesale distributor have to have a
marketing authorisation granted by the EU or by a Member State8. If the product is intended
to be exported see below.
Any distributor, not being the marketing authorisation holder, who imports a medicinal
product from another Member State shall notify the marketing authorisation holder and the
competent authority in the Member State to which the medicinal product will be imported of
his intention to import that product910.All key operations should be fully described in the
quality management system in appropriate standard operating procedures.
Qualification of Suppliers
5.1
Wholesale distributors must obtain their supplies of medicinal products only from
persons who are themselves in possession of a wholesale distribution authorisation, or
who are in possession of a manufacturing authorisation which covers the product in
question11.
5.2
Where the medicinal product is obtained from another wholesale distributor, wholesale
distributors must verify compliance with the principles and guidelines of good
distribution practices by the supplying wholesale distributor. This includes verifying
whether
the
supplying
wholesale
distributor
holds
a
wholesale
distribution
authorisation.12
5.3
Where the medicinal product is obtained from the manufacturer or importer, wholesale
distributors must verify that the manufacturer or importer holds a manufacturing
authorisation.13
5.4
Purchase of medicinal products should be controlled by written procedures. The supply
chain of medicinal products should be known and documented.
5.5
Appropriate qualification should be performed prior to any procurement. The selection,
including qualification and approval of suppliers is an important operation. This
operation should be controlled by a standard operating procedure and the results
documented and periodically rechecked.
8
Article 76(1), (2) of Directive 2001/83/EC
Article 76 paragraph 3 of Directive 2001/83/EC
10
Article 76, paragraph 3 of Directive 2001/83/EC
11
Article 80 point b of Directive 2001/83/EC
12
Article 80, 2nd paragraph of Directive 2001/83/EC
13
Article 80, 3rd paragraph of Directive 2001/83/EC
9
15
5.6
If the medicinal product is obtained through brokering, the wholesale distributor must
verify that the broker is registered and complies with the requirements in Chapter 1014.
5.7
Due-diligence should be carried out by the distributor when entering a new contract
with new suppliers in order to assess the suitability, competence and the reliability of
the other party to supply medicinal products. A risk based approach should be used for
this purpose considering:
i) searches for the new supplier’s reputation or reliability and its authorised activities;
ii)
certain
medicinal
products
are
more
likely
to
be
target
of
falsification;
iii) large offers of medicinal product which are generally only available in limited
quantities;
iv) out of range prices.
Qualification of Customers
5.8
Wholesale distributors must ensure they must supply medicinal products only to
persons who are themselves in possession of the distribution authorisation or who are
authorized or entitled to supply medicinal products to the public in the Member State
concerned.15 Qualification of customers should be appropriately documented.
5.9
Checks and periodic re-checks may include (but are not limited to): requesting copies of
customer's authorisations according to national law, verifying status on an authority
website, requesting evidence of qualifications or entitlement according to national
legislation.
5.10 Wholesale distributors should monitor their transactions and investigate any irregularity
in sale patterns to avoid diversion of medicinal products at risks of being misused and
to ensure fulfilling any public service obligation imposed upon them.
Marketing authorisation
5.11 Wholesale distributors wishing to distribute or distributing medicinal products in Member
State(s) other than the Member State in which the marketing authorisation was granted
should, on request, make available a copy of the marketing authorisation to the
national competent authority. Where appropriate, the competent authorities will inform
the wholesale distributor of any public service obligation imposed on wholesale
distributors operating on their territory.
Receipt of Goods
5.12 The purpose of the receiving function is to ensure that the arriving consignment is
correct, the medicinal products originate from approved suppliers and that they have
not been damaged or altered during transportation.
5.13 Where medicinal products require special storage or security measures, they should be
transferred to appropriate storage facilities immediately after appropriate checks have
been conducted.
14
15
Article 80 of Directive 2001/83/EC
Article 80 (c) of Directive 2001/83/EC
16
5.14 In the event of any suspicion of falsified medicinal product, the batch should
immediately be segregated and reported to the national competent authority and,
where applicable to the marketing authorisation holder16.
5.15 Batches of medicinal products intended for the Union market should not be transferred
to saleable stock before assurance has been obtained in accordance with written
procedures, that they are authorised and released for sale for the market in question.
For batches coming from another Member State, prior to their transfer to saleable
stock, the control report referred to in Art 51(1) of Directive 2001/83/EC or another
proof of release to the market in question based on an equivalent system should be
carefully checked by appropriately trained personnel.
5.16 Distributors receiving medicinal products from third countries for the purpose of
importation, i.e. for the purpose of placing these products on the EU market, must hold
a manufacturing/import authorisation17.
Storage
5.17 Medicinal products should be stored separately from other products and protected from
harmful effects of light, temperature, moisture or other external factors. Particular
attention should be paid to products where specific storage conditions are required.
5.18 Incoming containers of medicinal products should be cleaned, if necessary, before
storage.
5.19 Warehousing operations should ensure appropriate and good storage conditions and
allow the orderly storage of the various categories of medicinal products, products in
quarantine, and released, rejected, returned or recalled products as well as those
suspected to be falsified.
5.20 Steps should be taken to ensure stock rotation according to the expiry dates of batches
of medicinal products.
5.21 Medicinal products should be handled and stored in such a manner as to prevent
spillage, breakage, contamination and mix-ups. Medicinal products should not be stored
directly on the floor.
5.22 Medicinal products beyond their expiry date or shelf life should be withdrawn
immediately from saleable stock either physically or through other equivalent electronic
segregation. Physical removal of unsuitable stock should be performed regularly.
5.23 Stock inventories should be performed regularly. Timings should be defined using a risk
based approach. Irregularities should be investigated and documented.
Segregation of Goods
5.24 If required, medicinal products should be stored in segregated areas, which are clearly
marked and their access restricted to authorised personnel. Any system replacing
physical segregation such as electronic segregation based on a computerised system
shall provide equivalent security and should be validated.
16
17
Article 80 point i of Directive 2001/83/EC
Article 40, paragraph 3 of Directive 2001/83/EC
17
5.25 Segregation should be provided for the storage of rejected, expired, recalled or returned
products and suspected falsified medicinal products. The products and the areas
concerned shall be appropriately identified.
Destruction of obsolete Goods
5.26 Medicinal products intended to be destroyed should be appropriately identified, kept
separately and handled in accordance with a written procedure.
5.27 Destruction of medicinal products should be in accordance with national or international
requirements for disposal of such products, and with due consideration to the protection
of the environment.
5.28 Records of all destroyed medicinal products should be maintained.
Picking
5.29 Controls should be in place to ensure the correct product is picked. The product should
have an appropriate remaining shelf life when it is picked. It should be picked on a "first
expired first out" (FEFO) basis. The batch number should be recorded, where required.
Packing
5.30 Products should be packed in a way to avoid breakage, contamination and theft. The
packing should be adequate to maintain the storage conditions of the product during
transport. The containers in which medicinal products are shipped should be sealed.
Delivery
5.31 Deliveries should be made only to customers appropriately authorised or entitled to
receive medicinal products.
5.32 For all supplies to a person authorised or entitled to supply medicinal product to the
public, a document must be enclosed to ascertain the date; name and pharmaceutical
form of the medicinal product, batch number at least for products bearing the safety
features, where required; quantity supplied; name and address of the supplier, name
and delivery address of the consignee (actual physical storage premises, if different)
and applicable transport and storage conditions. Records should be kept so that the
actual physical journey undertaken by the product can be tracked.
Export
5.33 The export of medicinal products falls within the definition of "wholesale distribution"
18
.
A person exporting medicinal products must thus hold a wholesale distribution
authorisation or a manufacturing authorisation. This is also the case if the exporting
wholesale distributor is operation from a free zone.
18
Article 2(17) of Directive 2001/83/EC
18
5.34 The rules for wholesale distribution19 apply in their entirety in the case of export of
medicinal products, with the following exceptions20:
a.
The medicinal product does not have to be covered by a marketing authorisation of
the EU or a Member State;
b.
The customer does not have to be holder of a distribution authorisation;
c.
Moreover, where the medicinal product intended for exportation has been obtained
directly from another third country, without the product being prior to that placed on
the market (ie without prior import), the supplier does not have to bear a wholesale
distribution authorisation.
5.35 If the medicinal product is supplied to a person in a third country authorized or entitled
to supply medicinal products to the public, the rules for document enclosure apply as
for supply of the medicinal product established in the EU.21
19
Article 85a of Directive 2001/83/EC
Article 85a of Directive 2001/83/EC
21
Article 85a of Directive 2001/83/EC
20
19
Chapter 6 Complaints, Returns, suspected falsified
Medicinal Products and Medicinal Product Recalls
Principle
All complaints and other information concerning potentially defective medicinal products must
be collected and reviewed carefully according to written procedures. A special assessment of
returned medicinal product should be performed before any approval for resale. A consistent
approach amongst all partners within the supply chain is required in order to be successful in
the fight against falsified medicinal products. A system should be designed to recall products
known or suspected to be defective from the market in a prompt and effective manner. Any
return, rejection or recall operation should be recorded and records should be made available
to the competent authorities.
Standard Operating Procedures for handling product recalls and other similar situations should
be prepared, maintained, and implemented.
Complaints
6.1
There should be a written procedure in place for the handling of complaints. A
distinction should be made between complaints about the quality of a medicinal product
and those relating to distribution. In the case of a complaint about the quality of a
medicinal product, the manufacturer and/or marketing authorisation holder should be
informed without delay.
6.2
A person should be appointed for handling the complaints with sufficient supporting
personnel to assist him/her.
6.3
Any complaint concerning a potential product defect or a potential falsified product
should be recorded with all the original details and investigated. The national competent
authority should be notified without delay.
6.4
Any product distribution complaint should be thoroughly investigated.
6.5
If necessary, appropriate follow-up actions should be taken after investigation and
evaluation of the complaint.
Returned Medicinal Products
6.6
There should be written procedures for the handling and acceptance of returned
medicinal products.
6.7
A risk assessment should be performed taking into account the product concerned, any
specific storage requirements and the time elapsed since the medicinal product was
originally dispatched.
6.8
Returned medicinal products should be kept segregated from saleable stock until a
decision is taken regarding their disposition.
6.9
Medicinal products which have left the premises of the distributor should only be
returned to saleable stock if:
20
i) the medicinal products are in their unopened and undamaged secondary packaging
and in good condition;
ii) medicinal products returns from a customer not holding a wholesale distribution
authorisation should only be returned to saleable stock if they were returned within five
days of original dispatch;
iii) it is demonstrated that the medicinal products have been transported, stored and
handled under proper specified/predefined conditions;
iv) they have been examined and assessed by a sufficiently trained and competent
person authorised to do so;
v) the distributor has reasonable evidence that th the product was upplied to that
customer and the batch number of the dispatched product is known, that a copy of the
original delivery note is attached and that there is no reason to believe that the product
has been falsified.
6.10 Medicinal products requiring low temperature storage conditions can be returned to
saleable stock only if the batch number of the dispatched product is known and there is
evidence that the product has been stored within the authorised storage conditions
throughout the entire time. This evidence should include but is not limited to the
following:
-
delivery to customer
-
opening of the packaging
-
examination of the product
-
returning of the product to the packaging and sealing of the packaging
-
collection and return to the distributor
-
return to the distribution site refrigerator
6.11 All handling of returned medicinal products including their return to saleable stock or
disposal should be approved by the Responsible Person and recorded.
6.12 Products returned to saleable stock should be placed such that the "first expired first
out" (FEFO) system operates effectively.
Suspected falsified Medicinal Products
6.13 There should be documentation in place that describes how the distributor increases
their staff's awareness of the risks of falsified medicinal products entering the supply
chain.
6.14 Distributors must immediately inform the competent authority and, where applicable,
the marketing authorisation holder of the medicinal products they identify as falsified or
suspect to be falsified22. A procedure should be in place to this effect.
6.15 Any suspected falsified medicinal products found in the supply chain should be
immediately physically and securely segregated from legitimate medicinal products. All
products and relevant activities should be recorded.
22
Article 80 point i of Directive 2001/83/EC
21
Medicinal Product Recalls
6.16 There should be a written procedure for the management of recalls. The procedure
should be periodically tested.
6.17 Recall operations should be capable of being initiated promptly and at any time.
6.18 The distributor must follow the instructions of a recall message, which should be
approved, if required, by the competent authorities.
6.19 Any recall operation should be recorded at the time it is carried out and records should
be made available to the competent authorities.
6.20 The distribution records should be readily available to the person(s) responsible for the
recall, and should contain sufficient information on distributors and directly supplied
customers (with addresses, phone and/or fax numbers inside and outside working
hours, batches and quantities delivered), including those for exported products and
medicinal product samples.
6.21 Recalled medicinal products should be identified and stored separately in a secure area
while awaiting a decision on their disposition.
6.22 The progress of the recall process should be recorded and a final report issued,
including reconciliation between the delivered and recovered quantities of the medicinal
products.
6.23 The effectiveness of the arrangements for recalls should be evaluated regularly.
22
Chapter 7 Contract Operations
Principle
When outsourcing activities a written contract should be drawn up. Both the contract giver
and the contract acceptor must hold a distribution authorisation. The written and signed
contract should cover all wholesale distribution activities and clearly establish the duties and
responsibilities of each party. Written contracts should be established for any activity likely to
impact on GDP related activities.
Contract Giver
7.1
The Contract Giver is responsible for the activities contracted out.
7.2
The Contract Giver is responsible for assessing the competence of the Contract Acceptor
to carry out successfully the work required and for ensuring by means of the contract
and through audits that the principles and guidelines of GDP are followed. An audit of
the Contract Acceptor should be performed before the beginning of the outsourced
activities and afterwards audits should be done periodically.
7.3
The Contract Giver should provide the Contract Acceptor with all the information
necessary to carry out the contracted operations in accordance with the specific product
requirements and any other relevant requirements.
Contract Acceptor
7.4
The Contract Acceptor should have adequate premises and equipment, knowledge and
experience, and competent personnel to carry out satisfactorily the work ordered by the
Contract Giver.
7.5
The Contract Acceptor carrying out activities falling under the definition of wholesale
distribution of medicinal products is a wholesale distributor. As such, he is subject to all
obligations for wholesale distribution of medicinal products.
7.6
The Contract Acceptor should not pass to a third party any of the work entrusted to him
under the contract without the Contract Giver’s prior evaluation and approval of the
arrangements and an audit of the third party. Arrangements made between the
Contract Acceptor and any third party should ensure that the wholesale distribution
information is made available in the same way as between the original Contract Giver
and Contract Acceptor.
7.7
The Contract Acceptor should refrain from any activity, which may adversely affect the
quality of the product handled for the Contract Giver.
7.8
The Contract Acceptor must forward any information that can influence the quality of
the products to the Contract Giver in accordance with the requirement of the contract.
Contract
7.9
A written contract should be drawn up between the Contract Giver and the Contract
Acceptor, which specifies their respective responsibilities relating to the wholesale
23
distribution activities. Written contracts should be drawn up for any other outsourced
activity (e.g. cleaning, pest control etc).
7.10 The contracts should permit the Contract Giver to audit the Contract Acceptor at any
time.
24
Chapter 8 Self-Inspections
Principle
Self-inspections should be conducted in order to monitor the implementation and compliance
with GDP principles and to propose necessary corrective measures.
Self-Inspections
8.1
A self-inspection programme should be implemented to cover all aspects of GDP and
compliance with regulations, guidelines and operating procedures within a defined time
frame, whilst individual self inspections may be limited in scope.
8.2
Self-inspections should be conducted in an independent and detailed way by designated
competent person(s) from the company. Audits by independent external experts may
also be useful but should not be relied upon as sole means of self inspection to confirm
compliance with GDP.
8.3
Audit of subcontracted activities should be a part of the self-inspection programme.
8.4
All self-inspections should be recorded. Reports should contain all the observations
made during inspections. A copy of the report should be provided to the senior
management and other relevant persons. In the event that irregularities and/or
deficiencies are observed, their causes should be determined and the CAPA should be
documented and followed-up.
25
Chapter 9 Transportation
Principle
It is the responsibility of the wholesale distributor that, during the supply of medicinal
products, the transport conditions are such as to
maintain the quality of the product, to
protect against breakage, adulteration and theft, and to ensure appropriate environmental
conditions are maintained during transport.
Adequate precautions should be taken to this effect.
Medicinal products should be transported in accordance with the storage conditions indicated
on the packaging information.
Appropriate transport methods should be employed which may include transport by air, road,
sea, rail or a combination of the above. Regardless of the chosen mode, it should be possible
to
demonstrate
that
the
medicines
have
not
been
subjected
to
conditions
during
transportation that may compromise their quality. A risk based approach should be utilised
when planning transportation routes.
Transportation
9.1
The required storage conditions for medicinal products should be maintained during
transportation within the defined limits as described on the packaging information.
9.2
If a deviation has occurred during transportation, this should be reported to the
distributor and recipient of the affected medicinal products.
9.3
In cases where the recipient notices the deviation, it should be reported to the
distributor. Where necessary, the manufacturer of the medicinal product should be
contacted for information about appropriate steps to be taken.
9.4
It is the responsibility of the distributor to ensure that vehicles and equipment used to
distribute, store or handle medicinal products are suitable for their use and
appropriately equipped to prevent exposure of the products to conditions that could
affect their quality and packaging integrity, and to prevent contamination of any kind.
9.5
Delivery drivers (including contract drivers) should be trained in the relevant areas of
GDP.
9.6
There should be procedures in place for the operation and maintenance of all vehicles
and equipment involved in the distribution process, including cleaning and safety
precautions. Particular attention should be paid to the fact that cleaning agents should
not have an adverse effect on product quality.
9.7
Equipment used for temperature monitoring during transport within vehicles and/or
containers, should be maintained and calibrated at regular intervals at least once a
year.
9.8
Dedicated vehicles and equipment should be used, where possible, when handling
medicinal products. Where non-dedicated vehicles and equipment are used procedures
should be in place to ensure that the quality of the medicinal product will not be
compromised.
26
9.9
Deliveries should be made directly to the address stated on the delivery note and must
be handed into the care of the consignee. Medicinal products should not be left on
alternative premises.
9.10 In case of emergency deliveries outside normal business hours persons should be
designated and written procedures should be available.
9.11 If transportation is sub-contracted to a third party then the contract should encompass
the requirements contained within Chapter 7. In addition the contractors should be fully
aware of all relevant conditions applicable to the storage and transportation of medicinal
products.
9.12 Where transportation hubs are utilised in the supply chain, a maximum time limit of
normally 24 hours should be set to await the next stage of the transportation route.
Where medicinal products are held on the premises for longer than this defined time
limit, the hub will be deemed to be acting as a storage site and required to obtain a
wholesale distribution authorisation. For refrigerated product any storage at a
transportation hub for any period of time would require that premises to hold a
wholesalers distribution authorisation.
9.13 In the event that the transportation of medicinal products requires unloading and
reloading e.g. at terminals and hubs, these premises should be audited and approved
prior to deployment. Whenever any changes are made to the approved premises or
functions, attention should be paid to the continued suitability of the changed premises
or functions for their intended use. Particular attention should be paid to temperature
monitoring, cleanliness and the security of unguarded intermediate storage facilities.
Containers, packaging and labelling
9.14 Medicinal products should be transported in containers that have no adverse effect on
the quality of the products, and that offer adequate protection from external influences,
including contamination.
9.15 Selection of a container and packaging should be based on the storage and
transportation requirements of the medicinal products; the space required for the
amount of medicines; the anticipated external temperature extremes; the estimated
maximum time for transportation including transit storage at customs and the validation
status of the packaging and shipment containers.
9.16 Containers should bear labels providing sufficient information on handling and storage
requirements and precautions to ensure that the products are properly handled and
secured at all times. The containers should enable identification of the contents of the
containers and the source.
Transportation of Products requiring special Conditions
9.17 In relation to deliveries containing medicinal products requiring special conditions such
as narcotics or psychotropic substances, the distributor should maintain a safe and
secure supply chain for these products in accordance with requirements laid down by
the concerned Member States. There should be additional control systems in place for
delivery of these products. There should be a protocol to address the event of theft
occurring.
9.18 Transportation of medicinal products comprising highly active and radioactive materials
should be transported in safe, dedicated and secure containers and vehicles. In
27
addition, these safety measures should be in accordance with international agreements
and national legislation.
Temperature Control during Transport
9.19 Validated temperature-control systems (e.g. thermal packaging, temperature-controlled
containers, and refrigerated vehicles) should be used to ensure correct transport
conditions are maintained between the distributor and customer. Customers should be
provided with a temperature data to demonstrate that products remained within the
required temperature storage conditions during transit, if requested.
9.20 If refrigerated vehicles are used, the temperature monitoring equipment used during
transport should be maintained and calibrated at regular intervals or at a minimum of
once a year. This includes temperature mapping under representative conditions and
should take into account seasonal variations. Customers should be provided with data
to demonstrate that products remained within the required temperature storage
conditions during transportation, if requested.
9.21 If cool-packs are used in insulated boxes, they need to be located such that the product
does not come in direct contact with the cool-pack. Staff must be trained on the
procedures for assembly of the insulated boxes (seasonal configurations) and on the reuse of cool-packs.
9.22 There should be a system in place to control the reuse of cool-packs to ensure that
incompletely cooled packs are not used in error. There should be adequate physical
distinction between frozen and chilled ice packs.
9.23 The process for delivery of sensitive products and control of seasonal temperature
variations should be described in a written procedure. This procedure should also cover
unexpected occurrences such as vehicle breakdown or non-delivery. A procedure should
also be in place for investigating and handling temperature excursions.
28
Chapter 10 Specific Provisions for Brokers23
Principle
A "Broker" is a person involved in activities in relation to the sale or purchase of medicinal
products, except for wholesale distribution, that do not include physical handling and that
consist of negotiating independently and on behalf of another legal or natural person24.
Thus a person that procures, holds, supplies or exports medicinal products is never a broker.
This is independent of whether that person physically handles or stores the medicinal product.
Rather, a broker is a person who negotiates independently ( not as employee) and on behalf
of another person the sale or purchase of medicinal products.
Brokers are subject to a registration requirement. They must have a permanent address and
contact details in the Union under which they are registered. They shall notify the competent
authority of any changes thereof without unnecessary delay25.
By definition, brokers do not procure, supply or hold medicines. Therefore, requirements for
premises, installations and equipment as set out in Directive 2001/83/EC do not apply.
However, all other rules in Directive 2001/83/EC that apply to wholesale distributors also
apply to brokers. In particular, brokers must maintain a quality management system that
ensures applicable records are kept, efficient emergency plans for supporting recalls are in
place and that competent authorities are immediately informed of any suspected falsified
medicines offered in the supply chain26.
Quality System
10.1 The quality system of a broker should be defined in writing, approved and kept up-todate. It should set out the responsibilities, processes and risk management in relation
to their activities.
Personnel
10.2 Any member of personnel involved in the brokering activities should be trained in the
applicable EU and national legislation and in the issues concerning falsified medicinal
products.
Documentation
10.3 The general provisions on documentation in Chapter 4 apply.
10.4 In addition, at least the following procedures and instructions should be in place:
-
Procedure
Procedure
holders of
Procedure
for complaints handling;
for informing competent authorities and marketing authorisation
suspected falsified medicinal products;
for supporting recalls
23
Article 85b point 3 of Directive 2001/83/EC
Article 1, point 17a of Directive 2001/83/EC
25
Article 85b of Directive 2001/83/EC
26
Article 85b paragraph 1 of Directive 2001/83/EC
24
29
-
Procedure for ensuring that medicinal products brokered have a marketing
authorisation
Procedure for verifying that their supplying wholesale distributors hold a
distribution authorisation, their supplying manufacturers or importers hold a
manufacturing authorisation and their customers are authorised to supply
medicinal products in the Member State concerned.
10.5 Records should be kept for any transaction in medicinal products brokered at least the
following information:
-
date;
name of the medicinal product;
quantity brokered;
name and address of the supplier and the customer;
batch numbers of the medicinal product, where required.
30
Annex
Glossary of Terms
[ Industry is invited to provide list of terms to be included in the Glossary ]
Terms
Definition
Brokering
All activities in relation to the sale or purchase of medicinal products,
except for wholesale distribution as defined in point 17 of this article,
that do not include physical handling and that consist of negotiating
independently and on behalf of another legal or natural person
(Defined in Article 1 of Directive 2001/83/EC, as amended)
Exporting
All activities relating to the supply of a medicinal product to a state
other than a EU Member State or a Contracting State of the European
Economic Area.
Falsified medicinal
product27
Any medicinal product with a false representation of:
(a)
its identity, including its packaging and labelling, its name or
its composition as regards any of the ingredients including excipients
and the strength of those ingredients;
(b)
its source, including its manufacturer, its country of
manufacturing, its country of origin or its marketing authorisation
holder; or
(c)
its history, including the records and documents relating to
the distribution channels used.
Free zones and free
warehouses28
Free zones and free warehouses shall be parts of the customs territory
of the Community or premises situated in that territory and separated
from the rest of it in which:
(a) Community goods are considered, for the purpose of import duties
and commercial policy import measures, as not being on
Community customs territory, provided they are not released for
free circulation or placed under another customs procedure or
used or consumed under conditions other than those provided for
in customs regulations;
(b) Community goods for which such provision is made under
Community legislation governing specific fields qualify, by virtue
of being placed in a free zone or free warehouse, for measures
normally attaching to the export of goods.
Holding
Keeping or storing medicinal products
Procuring
Obtaining, acquiring, purchasing or buying medicinal products from
manufacturers, importers or other wholesale distributors
27
28
Article 1, point 33 of Directive 2001/83/EC
Articles 166 to Article 181 of Council Regulation (EEC) No 2913/92 of 12 October 1992 establishing
the Community Customs Code
31
Qualification
Action of proving that any equipment works correctly and actually
leads to the expected results.
The word validation is sometimes widened to incorporate the concept
of qualification.
(Defined in EudraLex Volume 4 Glossary to the GMP Guidelines)
Responsible Person
The responsible person is the qualified person designated as
responsible, meeting the conditions provided for by the legislation of
the Member State concerned,
(Defined in Article. 79(b) of Directive 2001/83/EC, as amended)
Supplying
All activities of providing /selling / donating medicinal products to
wholesalers; pharmacists; or persons authorised or entitled to supply
medicinal products to the public
Quality Risk
Management
A systematic process for the assessment, control, communication and
review of risks to the quality of the drug (medicinal) product across
the product lifecycle.
Quality System
The sum of all aspects of a system that implements quality policy and
ensures that quality objectives are met.
(International
Conference
on
Harmonisation
of
Technical
Requirements for Registration of Pharmaceuticals for Human Use, Q9)
Validation
Action of proving that any procedure, process, equipment, material,
activity or system actually leads to the expected results (see also
qualification).
(Defined in EudraLex Volume 4 Glossary to the GMP Guidelines)
Wholesale
distribution29
All activities consisting of procuring, holding, supplying or exporting
medicinal products, apart from supplying medicinal products to the
public. Such activities are carried out with manufacturers or their
depositories, importers, other wholesale distributors or with
pharmacists and persons authorized or entitled to supply medicinal
products to the public in the Member State concerned.
(Defined in Article 1 of Directive 2001/83/EC, as amended)
29
Article 1 point 17 of Directive 2001/83/EC
32